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    SEC
      LAW FIRM

    11693
      San Vicente Boulevard, Suite 357

    Los
      Angeles, CA 90049

    Tel.
      310-557-3059

    Fax.
      310-388-1320

    www.seclawfirm.com

    January
      31, 2007

    Kurt
      Murao, Esq.

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    Washington,
      D.C. 20549

    Re:
      NuWay
      Medical, Inc. Preliminary Proxy Statement on Schedule 14A Filed January 8,
      2007
      (SEC File No. 000-19709)

    Dear
      Mr.
      Murao:

    NuWay
      Medical Inc. (the “Registrant”) is responding to the written comments of the
      staff (the “Staff”) of the United States Securities and Exchange Commission (the
“Commission”) dated January 26, 2007 (the “Second Comment Letter”) and refers to
      the comments of the Staff of the Commission in its letter dated November 29,
      2006 (the “First Comment Letter”). The Registrant’s responses are keyed to the
      numbered comments of the Staff contained in the Comment Letter, which are set
      forth in full below, immediately preceding each response.

    General

    1.
      We
      note your response to comment 1 in our letter dated November 29, 2006 indicating
      that you have submitted a response to us on December 11, 2006. As further
      comments have been issued, please comply with any outstanding comments that
      were
      issued as part of our review of your Form 10-KSB for fiscal year ended December
      31,2005 and Forms 10-QSB for fiscal quarters ended March 31, 2006, June 30,
      2006
      and September 30, 2006.

    Response:
      The
      Registrant submitted its first written response to the Staff on December 11,
      2006 and its second written response to the Staff on January 26, 2007, and
      filed
      Amendment No.2 to its Quarterly Report on Form 10-QSB for the period ended
      September 30, 2007 on January 29, 2007.

    2.
      We
      note that you have included the bulleted representations that we requested
      at
      the end of the response letter. Please note that these representations must
      come
      from the registrant directly under separate cover.

    Response:
      The
      Registrant has filed the requested information under separate cover dated of
      even date.

    Proposal
      1, page 2

    Executive
      Compensation, page 8

    3.
      Please update and revise your disclosure to comply with the new executive
      compensation disclosure rules which went effective on November 7, 2006 for
      years
      ending on or after December 15, 2006. See SEC Release No. 33-8732A (August
      29,
      2006).

    Response:
      In light
      of the Staff’s comment and considering the virtual certainty that the
      Registrant, as a small public company with limited financial and personnel
      resources, could not comply with the expansive and extensive new executive
      compensation disclosure rules in a matter of just a few days, the Registrant
      has
      decided not to include the election of directors as an item for stockholder
      action at the upcoming meeting. Accordingly, the Registrant will delete Proposal
      1, the election of directors, from the proxy statement and also will delete
      Proposal 6, approval of the 2006 Stock Option Plan, and Proposal 7, ratification
      of appointment of auditor, from the meeting agenda. The Registrant will address
      these matters at its 2007 Annual Meeting of Stockholders. The upcoming meeting
      will be held as a Special Meeting of Stockholders, solely to address the
      transactional proposals, 2, 3, 4 and 5, which have been renumbered as Proposals
      1, 2, 3 and 4. In light of the foregoing, the Registrant respectfully requests
      that the Staff withdraw this comment at this time.

    Proposal
      2, page 13

    4.
      Please expand your disclosure to provide the information required by Item 303
      of
      Regulation S-K as to IOWC Technologies, Inc. See Item 14(c)(2) of Schedule
      14A
      and Item 17(b)(5) of Form S-4.

    Response:
      Regarding
      Item 14(c)(2) of Schedule 14A, as mentioned in response to the First Comment
      Letter, please be advised that the Registrant is not registering any shares
      of
      it common stock, because it is relying on the exemption from registration in
      Section 4(2) of the Securities Act of 1933, as amended and/or Regulation D
      promulgated thereunder in offering shares of its common stock to the company
      whose assets are being acquired, IOWC Technologies, Inc. (“IOWC”). IOWC is a
      Canadian corporation, whose shares of capital stock are owned by a single
      shareholder, Kenneth R. Code. IOWC will receive restricted securities in the
      transaction, the certificates for which will bear an appropriate legend. IOWC
      and Mr. Code, as its shareholder, will approve the sale of substantially all
      of
      its assets in accordance with the laws of Canada and/or the province of Alberta.
      Because the proposed transaction is structured as the sale of assets by IOWC,
      IOWC will continue to exist after the consummation of the transaction and will
      continue to have a single stockholder, Mr. Code. Therefore, the Registrant
      believes that providing a Management’s Discussion and Analysis or Plan of
      Operations (“MD&A”) for IOWC would not be meaningful to the Registrant’s
      stockholders. Instead, the Registrant proposes to include, and has included,
      a
“Plan of Operations After Consummation of the Transactions”, immediately
      preceding the pro forma financial statements contained in Proposal 2 (now
      renumbered Proposal 1). The disclosure is furnished in compliance with Item
      303
      of Regulation S-B, since the Registrant is a small business issuer as defined
      in
      Rule 405 promulgated under the Securities Act of 1933, as amended. The
      Registrant believes that this is a more meaningful disclosure for its
      stockholders to understand what the Registrant’s plans are and will be following
      the consummation of the transactions with IOWC. In light of the foregoing,
      the
      Registrant respectfully requests that the Staff modify its comment to permit
      the
      furnishing of a “plan of operations” in lieu of an MD&A for
      IOWC.

    Background
      of the BioLargo Transactions, page 15

    5.
      We
      note your response to comment 2 in our letter dated November 29, 2006.
Please
      expand your disclosure to more fully and specifically discuss the consideration
      negotiations between you and lOWC, including the relevant dates that resulted
      in
      the determination that you will issue a total of 553,475,300 shares of common
      stock for certain technology and rights relating to the BioLargo
      Technology.

    Response:
      The
      discussion contained under “Proposal 2 [now renumbered as Proposal 1] -
      Background of the BioLargo Transactions” has been expanded to include fuller
      discussion of the negotiations between the Registrant and IOWC with respect
      to
      the determination of the consideration to be paid by the Registrant to IOWC
      in
      the form of 553,475,300 shares of common stock for the BioLargo
      Technology.

    In
      connection with the foregoing response, the Registrant acknowledges
      that:

            ·

              It
                is responsible for the adequacy and accuracy of the disclosure in
                its
                filings;

            ·

              Staff
                comments of changes to disclosure in response to Staff comments do
                not
                foreclose the Commission from taking any action with respect to the
                filing; and

            ·

              The
                Registrant may not assert Staff comments as a defense in any proceeding
                initiated by the Commission or any person under the federal securities
                laws of the United States.

    Please
      respond to the undersigned with any further comments or any other communications
      regarding the Comment Letter.

              Very
                truly yours,

              /s/
                Lance Jon Kimmel

              Lance
                Jon Kimmel